Privacy Policies

When we say personal data, we mean any information that is about you or which can help identify you.

We may collect your personal data in a number of ways. You may provide personal data to us directly, or we may collect your personal data from third parties.

Information you provide to us

You may provide personal data to us when you contact us. This could be by email, letter, phone, or when you submit personal data online or via any of our applications or websites, e.g., Investor Centre, etc., or express an interest in obtaining information about us or our products and services. The types of information you provide to us will differ depending on the services we provide to you, but we will always only collect and process personal data required for the provision of services.

Other information we collect

Depending on the services we provide to you, we may also receive your personal data from other companies.

When you visit our websites or open emails from us, we collect information about your website use and email viewing so we can improve our services. For more information about how we collect this information please see our Cookie Policy.

You may also provide personal data to us about other individuals, such as joint account holders, family relations, individuals designated or authorised by you or the transferor or transferee of your shares. If you do this, you must confirm the other person agrees you may share their personal data with us and that we may use it in accordance with our privacy policies.

We use your personal data in the following ways depending on the services we provide, which are detailed in the relevant privacy policies:

• To maintain your account.
• To validate your identity and authenticate you.
• To deal with requests and transfers you send us.
• To respond to your queries.
• To provide you services and to enable us to provide services to our clients.
• To provide you updates on changes to our policies or terms and conditions.
• To determine if and when you have accessed email messages and web content provided by us.
• To detect, monitor, investigate, mitigate and prevent fraud, financial crime, suspicious or illegal activities.
• To enable us to provide services to the issuers or to you (as the case may be).
• To keep records and history of your holdings and any transactions that we facilitate on your behalf.
• To inform you of your rights.
• To disclose your data to the issuer(s) in which you hold securities.
• To analyse how people use our websites.
• For trend analysis to help us develop and improve our products and services.
• For profiling purposes to help us ensure that we provide you with the right information and offer you relevant services.
• If you agree, to update you on topics where you have requested this or contact you about other services and products we think may interest you.
• To comply with our legal and regulatory obligations.
• To monitor the security and use of IT systems.
• To deal with any complaints or legal claims.
• To manage our business in an efficient and proper manner, including the management of our financial position, our resources, the risks to which we are exposed and the way in which we arrange our internal operations.
• Other purposes as we set out in our Personal Information Collection Statement

Where we process your personal data, we need to have a valid legal basis for doing so. More detail is provided within privacy policies specific to services we provide, with the legal basis being one or more of the following:

• To perform our obligations under either a contract you have with us, or to take steps at your request before entering a contract with you or a contract we have with a client you have a relationship with (e.g., an issuer in which you have shareholdings or your employer where you are participating in any type of employee share plan).
• To comply with a legal obligation to which we are subject.
• You have given consent to processing for one or more specific purposes.
• The purposes of legitimate interests pursued by us or by a third party, and those interests are not overridden by your interests or your fundamental rights and freedoms.
• The performance of a task carried out in the public interest, for example financial crime screening.

Depending on the service we provide you, we may share your personal data with third parties where adequate safeguards are in place to protect your personal data.
We may share your personal data with:

• another entity in the Computershare Group.
• other companies to provide services to you or to help improve our services and products
• non-Computershare companies to whom we outsource the delivery of some of our services e.g., identity verification
• non-Computershare companies which help us with administrative services
• secure information storage and destruction providers
• companies you hold shares in
• our legal or other professional advisors, including our auditors;

and also:

• where requested to comply with our legal or regulatory obligations (which may include sharing information with regulators, government authorities, auditors, legal or other professional bodies or other public bodies).
• to help improve our services and products.
• to help us to perform our due diligence and other screening activities in accordance with our legal or regulatory obligations and risk management procedures. For further information about the sharing of your personal data and processing performed by the third party please see their privacy notice: https://www.refinitiv.com/en/products/world-check-kyc-screening/privacy-statement

For clarity, we will never sell your information for unsolicited marketing.

Where we share your personal information with third parties, all such parties will be obligated to maintain the confidentiality and security of your personal information and, except as may be required by law or governmental regulation, will be prohibited from further disclosing the information except in furtherance of the purposes for which it was disclosed, in which case such further disclosure will be subject to the same confidentiality and security obligations. We will not disclose your personal information to anyone outside these parties.

We keep your personal data for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal data to comply with our legal and regulatory requirements.

We may provide you with some services through another member of the Computershare group, or another company which is based in a country where data protection laws and standards differ from those in Hong Kong, including United Kingdom, India, Australia, and the United States.

Where we send your personal data to another country, we will ensure adequate measures are in place to safeguard it and to ensure you can exercise your privacy rights effectively.

Accessing your information

You may ask for a copy of the personal data we hold about you by writing to us at:

Computershare Hong Kong Investor Services Limited
Attention: Privacy Officer
Address: 17M Floor, Hopewell Centre, 183 Queen’s Road East, Wanchai, Hong Kong
Telephone Number: 852 2862 8555
Email address: PrivacyOfficer@computershare.com.hk

Correcting your information

We try to ensure all of your personal data is accurate. If you find any inaccuracies or if your details change, please notify us promptly and we will correct them.

Erasing or restricting use of your information

You may ask us to erase or restrict use of your personal data. If you do, we will comply with your request unless there is a legal reason for us not to (for example, if a law says we must retain records for a fixed period and to do so we must retain your personal data) or if it will impact the services we provide to you.

Withdrawing consent

We will not use your personal data for any new purpose which is not or is unrelated to the original purpose when collecting the data, unless with your express and voluntary consent. You can withdraw your consent previously given by written notice. Please note that if your consent is withdrawn, this may impact the services currently being provided to you.

Complaints

If you have any complaints about the way we use your personal data please contact our Privacy Officer who will try to resolve the issue.

You also have the right to complain to the Privacy Commissioner for Personal Data (“PCPD”).

Your data will be used to send you regular information about our products, services or events and to enable you to participate in those events, should you choose to do so. The legal basis for this processing is our legitimate interest as stated above.

The processing concerns the following personal data including but not limited to and where applicable:

• your full name
• details from your Hong Kong Identity Card, passport or other identification document; 
• your facial scan
• banking details
• email address
• phone number
• date of birth
• company name
• address data
• geo-location
• IP address
• Device ID
• Information relating to any shareholding you currently hold or intend to hold
• Your specimen signature
• details relating to your participation in an employee share plan (if you are a plans participant)

Your personal data is collected and processed by Computershare, affiliated companies and organisations where you have provided your consent to share your data with and with which Computershare has appropriate contractual arrangements in place.

We process and store your personal data as long as this is necessary for the fulfilment of the aforementioned processing purposes and in accordance with the relevant laws and regulations.

If there is any inconsistency or conflict between the English and Chinese versions, the English version shall prevail. Any Chinese version of this Privacy Policy is for reference only.